Control of Hazardous Energy: A Top OSHA Citation

Juliette Garesche

January 8, 2019

OSHA has had some form of Lockout/Tagout requirements on the books since the 1970s. The “Control of Hazardous Energy” regulations, in 29 CFR 1910.147, commonly called Lockout/Tagout (LOTO), but now updated to add Test Out (LOTOTO) have been in place since 1989. It is the most common OSHA citation at iron foundries, and the ninth most frequent citation at aluminum foundries.

The purpose of the regulation is to protect employees during service, maintenance, and repair activities against the unintentional start-up of equipment. Across all industries, the use of LOTOTO procedures are estimated to save 120 lives and prevent 50,000 injuries per year.

Many of the LOTOTO citations are for training violations. Three main groups of people must be trained.

Those authorized to conduct LOTOTO are usually from the maintenance department and they must be trained annually, skill tested annually, issued the proper equipment, and authorized by their employer to perform LOTOTO. Authorized employees must be trained to know all the LOTOTO steps, and they should be issued unique locks that only have one key. No person [with the possible exception of a supervisor, see 1910.147(e)(3)] may ever remove a lock they did not themselves place on equipment. If several people are working on a single piece of equipment, each person must apply their own lock.

Affected employees are those who work with equipment and machinery that may be locked out for service, usually by their Maintenance Department. Awareness level training must be offered to affected employees so they never attempt to defeat or remove locks from equipment and so they recognize tags and who to speak to if they want to use equipment that is locked out.

Finally, hired contractors who come on site to perform service and maintenance activities must coordinate with their host facility, so everyone is working cooperatively, implementing an effective LOTOTO plan. Contractors should not borrow equipment but should bring their own LOTOTO equipment with them.
Types of energy regulated by the LOTOTO standard are: electrical, mechanical, hydraulic, chemical, pneumatic, radiation, magnetic, steam, and potential energy.

Also consider stored energy that must be released. One of the few scenarios exempt from the regulation is equipment run by a single plug and cord under the exclusive control of the person performing maintenance. Another exception is if the maintenance involved a minor tool change or adjustment, if it is routine, repetitive, and integral to normal operations. If you think either of these exceptions may apply, read more at 1910.147(a)(2). Under no circumstances may an employee remove a guard or put a part of their body in harm’s way.

An effective LOTOTO program must be developed, documented, and used consistently. Group LOTOTO procedures must be developed for in-house employees and onsite contractors who service equipment.

An inventory should be conducted to identify all machinery and equipment that is powered by a source of energy. A full inventory must identify all sources of energy for each piece of equipment. A single piece of equipment may have several electrical connections, as well as gas lines and other sources of energy. Many types of devices can be used to isolate the energy from the equipment. Chains, valve covers, circuit breaker clips or locks, wedges, plug buckets, blank flanges, multi-user hasps, group lockout boxes and other devices must be purchased to fit your specific equipment. Typical steps for a lockout procedure are as follows:
• List all equipment to include and which types of shut-offs, locks and other equipment are needed to secure the machinery.
• Notify affected employees that you will be conducting LOTOTO, which equipment will be inaccessible, the expected duration of the work, and who to see if they have questions.
• Shut down the equipment in the usual manner. Involve the operating employees if possible.
• Disable the energy supplies and isolate the equipment from its energy sources.
• Apply locks and tags to the equipment.
• Release or block any stored energy. You may need to drain fluid, vent gas, discharge capacitors, cool equipment, block elevated parts, pin a part in place, or stop wheels from spinning before proceeding. Supply lines may need to be disconnected, blanked and blinded, or double blocked and bled.
• Clear workers, tools, and check the locks and isolation devices before attempting to start up the equipment to verify or test out that the equipment cannot be unintentionally started up. Remember to return the controls to “off” or “neutral” after this step.
• When work is done, or equipment is to be tested, all those who placed locks must each remove their own lock.
• Clear the area of affected employees, rags, tools, and other supplies, before starting up the equipment.

OSHA requires a significant amount of training for authorized employees. Initial and annual training requirements are outlined in the regulation. The entire program must be reviewed annually to identify weaknesses or practices that have become sloppy or don’t follow the protocols. Some of the more frequently cited elements are the lack of energy control procedures, insufficient documentation of training, lack of proper equipment on site, or a lapse in implementation of the program. Many companies have had success in having the maintenance staff involved in development of the procedures. Using photos of each shut-off is helpful.

Often fastening laminated sheets at each piece of equipment encourages the use of the written procedures.

The Center for Disease Control’s National Occupational Research Agenda released an online resource guide to create written procedures for hazardous energy control at www.cdc.gov/nora/councils/manuf/loto/guide.html.

If the LOTOTO procedures are used as required, they will protect employees from serious injury. Remember, there is never a good reason to take short cuts with LOTOTO. Zero energy will result in zero incidents.

Click hereto see this story as it appears in the January 2019 issue of Modern Casting